Vague allegations lacking the essential ingredients of the charged offences cannot sustain an FIR.

The second respondent, a manager of Santhi Feeds (P) Ltd., alleged that on 11 January 2026 the petitioners obstructed company vehicles transporting chicks, intercepted a vehicle, pelted stones at it, damaged it, and threatened its driver and cleaner.

The petitioners said they were farmers’ organisation members seeking higher poultry-protection wages and that the vehicle stoppage was part of a previously announced, non-violent production-stoppage strategy.

They sought to quash the FIR under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

The judgment identifies the FIR as Crime No. 10 of 2026 in its heading and operative order, but paragraph 4 refers to Crime No. 24 of 2026.

1. Whether the allegations disclosed the ingredients of rioting and wrongful restraint under Sections 191(2) and 126(2) of the Bharatiya Nyaya Sanhita, 2023.

2. Whether the allegations disclosed the ingredients of an offence under Section 296(b) or criminal intimidation under Section 351(3) of the Bharatiya Nyaya Sanhita, 2023.

3. Whether the FIR was liable to be quashed as an abuse of process, including on the ground of mala fides.

The Court considered Sections 191(2), 126(2), 296(b) and 351(3) of the Bharatiya Nyaya Sanhita, 2023, and Section 5 of the Tamil Nadu Public Property (Prevention of Damage and Loss) Act, 1992, as the provisions invoked in the FIR.

It stated that rioting requires an unlawful assembly, a common object and force or violence in furtherance of that object; wrongful restraint requires restraint of a person from proceeding in a direction in which that person has a right to proceed; and Section 296(b) requires obscene words or songs in or near a public place and annoyance to others.

For criminal intimidation under Section 351(3), the Court identified a threat and an intention to cause alarm, with the further statutory purpose of compelling an act or omission.

It relied on K. Jeyaramanuju v. Janakaraj & Anr., 1996 (1) CTC 470, for the proposition that obscene words alone do not establish the offence under Section 294 IPC without proof of annoyance.

It relied on the category concerning mala fide proceedings in State of Haryana v. Bhajan Lal, (1992) Supp. (1) SCC 335, as quoted in the judgment, in considering quashing.

The Court treated the allegations against the petitioners as vague and omnibus, finding no sufficiently specific allegation of an unlawful assembly, common object or violence attributable to them, and no particulars showing that they personally restrained anyone.

It found no identified obscene words or evidence that anyone was annoyed, and considered the alleged threats to be empty and without effect on the complainant.

Applying the Bhajan Lal category concerning mala fide proceedings, it characterized the FIR as an abuse of process and held it unsustainable.

The judgment does not separately explain its application of Section 5 of the Tamil Nadu Public Property Act to the allegation of vehicle damage.

The connected miscellaneous petition was closed.